117 Yale L.J. 120 (2007).

This Note assesses the relationship between hostile work environment harassment and retaliatory harassment claims by reviewing several cases in which both claims were brought. It argues that courts have unjustifiably narrowed the reach of both claims by disaggregating harassment from retaliation in a variety of ways, including considering harassment that occurs after the discrimination complaint to be solely retaliatory, rather than both retaliatory and discriminatory; interpreting harassment to be motivated simply by personal animus rather than by a retaliatory or discriminatory purpose; and disaggregating explicitly racialized or sexualized forms of harassment from nonracialized or sexualized forms of conduct. This Note concludes by describing the potential of joint harassment/retaliation claims to respond to both status-based and conduct-based discrimination and by offering specific recommendations to courts for reaching an integrated understanding of the two claims.